Does the ADA cluster rule apply to a 3-day festival on private land?
We're planning a craft beer festival on our 50-acre farm next month. The event runs three days, with about 1,200 guests a day. We've got a mix of standard portable toilets and one large restroom trailer with flushing toilets. The ground is level pasture, and the service truck can drive right up to the units.
Our city permit office told us we don't need to provide an ADA-compliant unit because the event is on private property. That doesn't sound right to me. I thought the ADA 5 percent cluster rule applied to any temporary event open to the public, regardless of who owns the land. Has anyone else run into this? Are there exceptions for private property when you're selling tickets to the general public?